IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 2103/MUM/2025 Assessment Year: 2022-23 Fort Canning Investments Assistant Commissioner of Pte. Ltd. Income-tax (International

260 Orchard Road, #14-02 taxation) - 2(3)(1)

Vs.

The Heeren, Singapore, Mumbai Singapore – 238855 (PAN: AACCF9284G)

(Appellant) ( R e spondent)

ITA No. 2104/MUM/2025 Assessment Year: 2022-23 Fort Canning Credit Assistant Commissioner of Investments Pte. Ltd. Income-tax (International

260 Orchard Road #14-02 taxation) - 2(3)(1)

Vs.

The Heeren, Singapore, Mumbai Singapore – 238855 (PAN: AADCF7866R)

(Appellant) ( R e spondent)

Present for:

Assessee : Shri Dhanesh Bafna, Ms. Priyanka Agarwala, Ms.Hirali Desai, Ms. Nidhi Agarwal and Shri Yogesh Malpani, CAs Revenue : Shri Satya Pal Kumar, CIT DR and Shri Krishna Kumar, Sr. DR Date of Hearing : 29.10.2025 Date of Pronouncement : 27.01.2026 AY 2022-23

O R D E R

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These appeals filed by the assessee are against the assessment order passed under the directions of Dispute Resolution Panel-1 (DRP), Mumbai, vide order no. ITBA/DRP/F/144C(5)/2024- 25/107